In the 1949 film Adam's Rib, often classified as a screwball comedy, assistant district attorney Adam Bonner (Spencer Tracy), surprisingly finds his wife opposing him in the courtroom. Defending a woman accused of assaulting her unfaithful husband, attorney Amanda Bonner (Katharine Hepburn) attempts to reread and reshape the law to reflect progressive values, part of the postwar discourse surrounding the "New Woman." Although he considers himself to hold these same values, Adam regards his wife's actions as an assault upon law and, by extension, a challenge to himself. Defensive and significantly weakened in the face of Amanda's courtroom strategies, Adam lectures his wife in no uncertain terms: "Contempt for the law, that's what you've got. It's a disease, a spreading disease. . . . The law is the law. . . . You start with one law, then pretty soon it's all laws, pretty soon it's everything; then it's me."

Simply by virtue of her status as a politically progressive career woman in post-World War II America, Amanda poses a threat that filters beyond the public arena and into the private sphere, a dichotomy strongly inscribed in American legal discourse and ideology since the Constitution and only lately challenged. Taking center stage against her husband in the space traditionally designated as his, Amanda's actions threaten Adam's potency both in the courtroom and in the bedroom, it seems, resulting in the temporary breakup of their marriage. Amanda destabilizes her designated space within the private sphere of the home directly as a result of her successful performance in the public theater of the courtroom.

Yet the danger Amanda poses ultimately is contained. Although she challenges the jury and the film audience to question basic assumptions about justice and gender—asking the jury to imagine the accused woman as a man defending his home and the husband as an unfaithful wife whose actions threaten family stability—she nevertheless argues in terms of traditional family ideology: "An unwritten law stands back of a man who fights to defend his home. Apply this same law to this maltreated wife and neglected woman—we ask you no more—equality." After winning in the courtroom, however, Amanda comes to understand and regret her miscalculation in terms of her own marriage. During a meeting with their accountant to divide their taxable receipts, she and Adam eventually do reconcile, the family thus reconstituted under the power of property and tax law.

Adam even manages to nullify Amanda's powerful courtroom argument in a comic scene during their separation, when he jealously interrupts what he believes to be a romantic liaison between Amanda and one of their neighbors. Bursting into the apartment, (licorice) gun in hand, Adam tricks Amanda into reacting. "You have no right," she shouts, thus admitting the ethical fallacy upon which her rational courtroom argument had been constructed. Amanda's sense of accomplishment in her courtroom victory is tempered further by a nagging discomfort and guilt arising from her husband's courtroom defeat. She has since learned only to joke about opposing him in an election for county court judgeship.

The threat has been contained, but with something of a difference. Adam's Rib simultaneously reflects anxieties about the post-World War II New Woman but also mediates an uneasy acceptance of this new state of affairs. The film spectator is encouraged to agree with Adam when he pronounces his wife a threat to the law and by extension to their marriage, yet the viewer also is allowed to recognize, if only for a moment, the validity of Amanda's courtroom argument. In contemporary films representing female lawyers, the case has become somewhat more complicated.

Although films involving female lawyers appeared in American film as early as the 1920s, more than twenty appeared once again in the decade from the mid-1980s through the mid-1990s, the period that is the focus of this study. Beginning with two early 1980s comedies—Seems Like Old Times (1980) and First Monday in October (1981)—the female lawyer film has taken on relatively consistent codes of theme, structure, and representation, particularly following the 1985 release of Jagged Edge. In many respects, Jagged Edge establishes the tone for a majority of female lawyer films to follow, both in its representation of the female lawyer and in its hybrid status, merging, in this case, the courtroom drama with the psychological thriller and aspects of the maternal melodrama.

Produced in rapid succession, female lawyer films are simple in narrative form, encouraging critics, on first viewing, to regard them as Hollywood fluff or formula, in much the way B-movies and women's films of the past were dismissed as inferior productions or "weepies" by their contemporary critics. Beneath the simple form of the female lawyer film, however, lie two revealing oppositional tendencies. One is the popularly held idealized vision of law—that the law is a stable, immutable force beyond the reach of transitory political and cultural influences. This notion becomes complicated by a second factor—the political and cultural context registering a troubled or uneasy acceptance of women in law. Together, these two conditions create some difficulty in resolving the "problem" of women in law.

As we consider the body of 1980s and 1990s female lawyer films, two intertwining questions arise: why does the 1980s become the decade giving rise to so many female lawyer films, and why is law the chosen profession for a clear majority of Hollywood's female protagonists of the period? In partial answer to both questions, it is important to note another oppositional tendency in films featuring female lawyers. While these films powerfully mediate what many film critics and historians have identified as an "antifeminism" pervasive in Hollywood films of the period, they also register a "crisis of masculinity" many see at the core of this antifeminism. Film historian Robert Sklar rightfully points out that "the nature of masculinity is to be in crisis," going on to observe, however, that "in the 1980s traditional notions of maleness appeared to be under particularly severe challenge in the United States" (Sklar 1994, 345). In the female lawyer film this crisis reaches beyond anxieties concerning simple "maleness" as a performative expression of gender identity to a more deeply rooted cultural crisis of patriarchy—one that spills over from the 1980s and into the 1990s.

Films focusing on female lawyers provide unusually fertile ground for exploring a patriarchy in crisis, for with law at the core of contention, patriarchy itself is called to question. Yet, in keeping with the ideological limitations often dubbed as "Hollywood liberalism," in which films appearing to mount an ideological critique often end up supporting the very systems they call into question, the figure of the female lawyer is often positioned to deflect the very analysis of patriarchal power her existence would seem to prompt. In foregrounding the status of the female lawyer, these films displace overt interrogation of patriarchal power and its uses, by placing the female lawyer on trial, interrogating her role as woman and as lawyer.

Ostensibly feminist in their very positioning of a female lawyer as protagonist, films of the 1980s and 1990s paradoxically reveal her failure in "measuring up" to the liberalism the films themselves superficially adopt. The liberal, feminist political façade of the female lawyer film often crumbles to expose deeply conservative, antifeminist underpinnings, the films thus becoming symptomatic of the very crisis they wish to submerge—but not without revealing subtle and telling contradictions.

Hollywood Trends and the Female Lawyer Film

While the overall number of films featuring female protagonists in the 1970s and 1980s represents a small fraction of the total number of films produced in Hollywood during that period, the second half of the 1970s saw a number of films addressing women's issues, among them: Alice Doesn't Live Here Anymore (1974), An Unmarried Woman (1977), Julia (1977), The Turning Point (1977), Coming Home (1978), Girlfriends (1978), and Norma Rae (1979). Growing out of laissez-faire attitudes toward both industrial takeovers and enforcement of the Paramount ruling, as well as a new emphasis on "synergy," demands for increased production and greater variety arose in Hollywood of the 1980s (Sklar 1994, 339-341). So, too, was there a carryover from the interest of the mid-1970s in strong female protagonists—at that time a response to the general visibility and consciousness-raising efforts of the women's movement. Yet, while a film like An Unmarried Woman met with moderate box office success, it also revealed the limitations of Hollywood feminism, which, as film scholars Michael Ryan and Douglas Kellner explain, "expunges all radicalism from feminism and repackages it as a 'new woman' or 'corporate' feminism which equated liberation from patriarchy with enlistment in its ranks" (Ryan and Kellner 1988, 144), a pattern at the core of many female lawyer films to follow.

At the same time as the industry felt a need to create "interesting" roles for women in the mid-1970s, it also cracked open its door, though ever so slightly, to women directors. These filmmakers (including Elaine May, Joan Micklin Silver, and Barbara Loden), however, often were assigned "women's projects," which they considered both limiting and expressive of a male-dominated industry that held onto stereotypical notions about the interests and capacities of female directors (Hillier 1994, 124). Moreover, with the notable exceptions of Sherry Lansing and Dawn Steel, two powerful producers in the 1980s and early 1990s, neither of whom were strongly committed to feminist projects, women in the industry generally held middle-management positions without the power to "green light" proposed projects and with few rising to positions of genuine power (Hillier 1994, 122). At the same time, however, the industry recognized the box office potential of an unusual group of talented and powerful female stars of the period, some of whom were overtly political, others of whom were perceived as "strong women" helping to shape the roles they played. Among these women were actors who eventually would take on roles as female lawyers: Jill Clayburgh, Glenn Close, Debra Winger, Ellen Barkin, Cher, Jessica Lange, Barbara Hershey, Susan Sarandon, and Michele Pfeiffer—as well as those who have yet to play female lawyers: Meryl Streep, Sigourney Weaver, and Geena Davis.

Given the pressure for variety, for quick turnover of product, and for stronger female roles, yet the reluctance to allow female directors, producers, and actors the autonomy to develop their own projects, Hollywood began repackaging successful genres of the past with the new twist of a female lead. The 1980s and 1990s saw the production of the female sci-fi action film, with the Alien and Terminator series, among others; the reappearance of westerns, now featuring female leads in The Ballad of Little Jo (1993), Bad Girls (1994), and Buffalo Girls (1995); the appearance of the female "buddy" film, with Thelma and Louise (1991), or the female-male buddy film, with The Pelican Brief (1993), Speed (1994), and Fair Game (1994). Female cops appeared on the scene with Blue Steel (1990), and female FBI agents with Black Widow (1987) and Silence of the Lambs (1991).

The numbers of female lawyer films that were produced, in part, grew out of this recycling trend and from the synergistic influence of television shows featuring female lawyers as central characters. It is important to note, however, that many female lawyer films are genre hybrids involving more than simple replacement of a male lead with a female lead. The Pelican Brief, for instance, combines elements of the thriller and buddy film with the female lawyer film (technically, the female lead is a law student), just as Adam's Rib had earlier combined elements of the screwball comedy and courtroom drama. In the 1980s the classic male lawyer formula, often incorporating elements of the courtroom drama, supplied serious female actors with substantial roles. On the surface, then, the female lawyer film answered a feminist call for women in professional, nontraditional roles. And while the films did not command box office earnings as high as those of 1990s male lawyer films to follow or of dual-focus films involving both male and female lawyers, films of the 1980s and 1990s featuring female lawyers as protagonists earned solid box office receipts, with a few exceptions.

But in Hollywood's attempt to create interesting roles for women, whether in recycled genre films or nongenre projects, "interesting" has been defined in the context of a male-dominated industry and, in the mid-1980s, was further defined within a context of New Right "backlash" attitudes toward the women's movement of the 1970s and early 1980s, leading film scholar Robin Wood to observe that "the precariousness of what was achieved in the 70s can be gauged from the ease with which it had been overthrown in the 80s" (Wood 1986, 206).

A brief look at three modestly successful films of the decade illustrates the antifeminist stance growing out of these conditions. Ordinary People (1980), Fatal Attraction (1987), and Broadcast News (1987), like many other films of the period—in their respective focus on family, female sexuality, and independent professional women—display a thin veneer of liberalism that barely covers reactionary underpinnings. Each one reflects a concern central to the female lawyer films of the decade: Ordinary People examines the woman as mother; Fatal Attraction links aggressive, pathological sexuality with a career autonomy; and Broadcast News pits the female protagonist's professional competence and accomplishments against her desire for personal fulfillment. Very much like male-centered 1980s films devoted to the "restoration of the father," as Wood describes this tendency in the Star Wars and Indiana Jones series (Wood 1986, 174), and as Susan Jeffords describes it in the Back to the Future series (Jeffords 1994, 67-69), the female-centered films of the 1980s undermine their female characters in order to restore the father to his "rightful" place—be it within the context of family or within the symbolic context of phallocentric institutions where patriarchal authority must be stabilized. Heralding the coming of the Reagan era, a film like Kramer vs. Kramer (1979), for instance, suggests, as Ryan and Kellner observe, that "a man can both mother and work successfully. The question it poses implicitly is 'Why can't a woman do the same?'" (Ryan and Kellner 1988, 159). Several female lawyer films pose nearly the same question.

Beyond their frequent failure as mothers, career women in 1980s films are represented as professionally inadequate, either blurring the lines of ethical and legal conduct when carrying out their work, or adhering too rigidly or obsessively to ethical principles, as does Jane (Holly Hunter), who, in Broadcast News, is forced to choose between a professional defense of ethical journalistic practice, on the one hand, or personal happiness on the other—with no sense that as a female professional she can hope to attain both. As Elayne Rapping points out, films like Broadcast News, by focusing ostensibly on journalistic or other public issues, "submerge reactionary attitudes toward women in narratives that hang on the resolution of some other matter entirely, one posed as more weighty than mere matters of wedding and bedding" (Rapping 1989, 6). Among the other films that Rapping places in this category are The Good Mother (1988) and Running on Empty (1988), which assume a woman's right to "any number of good and important things" but then "proceed to undermine their heroines' rights to equality, dignity, justice, meaningful work, and sexual fulfillment, anyway, and to imply, yet again, that marriage and family are women's best hopes." Rapping suggests that this more subtle approach, one taken up by many female lawyer films of the period, is "more demeaning and dangerous than the more blatant anti-feminism of the day" (Rapping 1989, 6).

A more overt antifeminism expresses itself in Ordinary People and Fatal Attraction. A cold, unloving mother is shown to be at least partially responsible for her son's suicidal tendencies in Ordinary People, and her expulsion from the family makes possible a hopeful ending in which the warm and loving father can nurture his son back to health and stability, illustrating Wood's observation that "the mother becomes superfluous to Oedipal/patriarchal concerns, a mere burdensome redundancy" (Wood 1986, 173). And Fatal Attraction's independent professional woman takes on qualities of a horror film monster—refusing to die, even after suffering repeated stabbings. It is the "good mother" (Anne Archer), a full-time suburban housewife, who finally has the power to eliminate this sexually transgressive woman threatening to destabilize the middle-class family. In its cautionary tone and absence of irony, the final moments of this film support its Reagan-era ideology: although the father transgresses in his brief affair, his "rightful" role as head of household is restored and his own brutality in expelling this "other woman" in support of family is legitimized. Like Fatal Attraction, a number of female lawyer films imply, at their core, that women threaten the patriarchal order, and for that they must be punished.

New Right Demands on Real and Reel Female Lawyers

The consistent production of so many female lawyer films, beginning in the mid-1980s when the Reagan New Right had firmly established itself, suggests something more, then, than a Hollywood need to satisfy demands for "progressive" representations of women in powerful, professional roles. It seems no coincidence that the bulk of these films either were produced or were in the works during the Reagan-Bush administrations, which established an agenda of containment around feminist issues, devoting verbal support to women's rights while undermining women through legislative activity and attitudes touting "family values." If anything, this group of films, like others of the period, reflects the New Right approach to women's and minority issues—a superficial proclaiming of support, sometimes even displaying rare individual success stories to exhibit a forward-thinking position on such issues, meanwhile a forging of policies to undermine genuine empowerment of such groups.

In her book Women Lawyers: Rewriting the Rules, political scientist and lawyer Mona Harrington frames the highly charged issue of women in law in the 1980s and 1990s within the debate around multiculturalism and conservative resistance to multicultural demands, citing the 1992 Republican National Convention as the moment "when speakers . . . openly declared a cultural war on groups seeking social change—feminists, homosexuals, single parents, working mothers, and obstreperous racial minorities" (Harrington 1994, 5). Similar tensions inform the majority of female lawyer films, yet these films carefully conceal, or perhaps remain unconscious of, their own underlying reactionary attitudes. As if the organizers of the 1996 Republican National Convention had seen a few too many female lawyer films, all energies were poured into constructing a façade of acceptance, most notably in choosing a woman, Representative Susan Molanari of New York, as keynote speaker. While her presence painted the Republican Party as inclusive and supportive of women's issues, her message served only to reinforce the New Right agenda, with repeated references to home, family, and her central role as mother. Invoking the values held by three generations of her own family, she concluded with an image of rocking her daughter to sleep and wondering "what her life is going to be like" (Molanari 1996, A18). In this case, the very public conservative politician consistently represented herself as inhabiting the private sphere of the home almost exclusively, conforming to the ideal of the "New Traditional Woman," a concept arising from the pro-family movement of the 1970s.

In their similar need to adopt a superficially liberal or accepting stance, female lawyer films mediate deeply rooted contradictions within the politics of patriarchy and its response to feminism—contradictions evident not only within a Republican "New Right," as represented by Reagan and Bush, but also within the politics of Democratic presidents Carter and, later, Clinton, as well as some branches of feminism itself. Like Amanda Bonner in Adam's Rib and former congresswoman Susan Molanari, the female lawyer, in both contemporary film and culture, occupies a rather conflicted position. O. J. Simpson prosecutor Marcia Clark, who was forced to undergo a transformation to make her more juror- and media-friendly, is one notable real-life example. The "packaging" of Marcia Clark by jury consultants included their advice that she speak about "domestic themes" to the press—"themes like grocery shopping and children . . . crucial tools in the makeover and motherization of Marcia Clark," which one consultant felt necessary, "since both male and female jurors are put off by tough female lawyers." Another consultant said of Clark, "She took to heart what the research has shown: that she's coming across as too hard, too cold" (Margolick 1994, A10). During the 1992 presidential campaign, another female lawyer, Hillary Rodham Clinton came under severe attack as a woman for whom professional ambitions appeared to eclipse household concerns, forcing her, like Clark, to construct a more domestic image in the media, extending to her taking on the surname of her husband. The female lawyer may have the power to operate within the legal arena, yet her success, it seems, is contingent upon her declaiming a stronger desire for fulfillment in the private sphere of home and family.

A brief look at the political climate surrounding debates on the Equal Rights Amendment (ERA), from its 1972 passage in Congress through its ultimate failure to achieve ratification in 1982—and its relationship to similar debates involving women's rights in the immediate post-World War II era, to be treated in the section that follows—sheds light on the cultural contradictions resulting in such paradoxical representations. While the ERA passed by an overwhelming majority in the 1972 Congress and won ratification in thirty-two states within a year, the amendment was three states short of adoption when its ratification deadline passed in June 1982. Largely as a result of efforts by the New Right and the religious right, the amendment was defeated. Rebecca Klatch examines the attitudes of both groups, who felt confirmed in their belief that American society was sinking into chaos and moral decay as a result of the 1960s civil rights and antiwar movements, the sexual revolution, and the drug cult (Klatch 1995, 259-260). The New Right believed that at the core of this social rebellion and political dissent was an attack on its most sacred institution—the family. Central also to the disintegration of the family, from the perspective of the New Right, were the increasing numbers of women—especially wives and mothers—working outside the home, giving rise to "a new emphasis on self" and the "ushering in of the Me Decade of the 1970s" (Klatch 1995, 261). Such perceptions, according to Klatch, supplied ammunition for New Right attacks on women who wanted guarantees the ERA provided, for these guarantees were seen as simply one more expression of self before others, tearing away at the social fabric of American life. From a speech that hauntingly echoes Spencer Tracy's lines in Adam's Rib, Klatch quotes a local pro-family activist who proclaimed, "The libbers want to abolish the family. . . . But the family is the basis of everything. It is the foundation of our society; if that crumbles, everything else goes" (Klatch 1995, 262). New Right anti-ERA activists Phyllis Schlafly and Paul Weyrich organized their opposition through an attack upon gay rights and upon diverse definitions of family, arguing that such "perverse" thinking "has resulted in people trying to pass off as legitimate families, illegitimate lifestyles" (Klatch 1995, 263).

Intertwined with the conservative defense of the traditional family was a strongly inscribed public/private division, except when a redefining of the private sphere was seen to undermine the conservative agenda. The New Right further attacked feminists and the ERA on the basis that they were seen to devalue and challenge the right of women who wished to remain at home to care for their children. Fueled by opposition to the 1973 Roe v. Wade ruling, the New Right painted a picture of ERA supporters and feminists as women who would stop at nothing less than "infanticide" in attempting to achieve self-actualization (Klatch 1995, 265-270). The New Right found even firmer ground for opposing the ERA by claiming that the ERA translated into Big Government.

These New Right arguments prevailed in the battle to defeat the ERA, and such arguments, circulating in the early 1980s and beyond, inform female lawyer narratives, in spite of the ostensibly liberal political position adopted by many of the films. Exploring similar limitations of liberalism with regard to feminist issues, political scientist Zillah Eisenstein interprets President Carter's 1979 firing of Bella Abzug as co-chair of the National Advisory Committee on Women, for instance, as his attempt "to demobilize the radical faction of the liberal feminist movement" (Eisenstein 1984, 24). Eisenstein further suggests that "Abzug's dismissal was an effort by Carter to legitimize further the narrow legalistic interpretation of the ERA, rather than the broader view that connects women's rights to questions of the economy, abortion, and homosexuality" (Eisenstein 1984, 25).12

Writing during Reagan's presidency and referencing his appointment of Sandra Day O'Connor as the first woman justice of the Supreme Court, Eisenstein further analyzes the failure of the ERA as symptomatic of a political atmosphere that attempts to both profit from and undermine feminist issues, pointing out that while Carter passively supported the ERA, Reagan claimed to oppose the amendment but to support equal rights: "Reagan argues that the amendment would be harmful to women because it will treat men and women as though they were the same (equal?). On the other hand, the appointment of O'Connor was supposed to prove that a woman is free to be anything she wants to be. All women need is freedom of choice—not equality" (Eisenstein 1984, 131-132). Eisenstein's reading suggests an atmosphere ripe for the emergence of the female lawyer film and, in many ways, illustrates the underlying political thrust of such films. Reagan envisioned using O'Connor, a female judge, to advance his conservative agenda and strengthen the patriarchal status quo, yet, in so doing, appeared to support women's rights. Further ironies emerge in light of the discrimination that O'Connor herself experienced as a young lawyer who found that major firms were willing to hire her only as a legal secretary, despite her outstanding record at Stanford Law School (Rhode 1989, 55).

In 1981, the very year of O'Connor's nomination to the Court, First Monday in October appeared, a film centered upon the first female nominee to the Supreme Court. First Monday in October displays its narrative premise as liberal and forward-thinking, yet gradually reveals its own underlying conservatism. Not unlike O'Connor, the film's Supreme Court justice may be the first woman to serve on the Court, but as a conservative she seems dedicated to protecting the patriarchal foundations of that institution.

"Placing" the Female Lawyer: Perceptions of Law and Difference

If law is "a paradigm of maleness," as feminist legal theorist Janet Rifkin argues (Rifkin 1993, 412), then the female lawyer film is a site where cultural attitudes about women, patriarchy, and the power of law converge. The female lawyer film, moreover, strongly registers the anxieties arising when law, patriarchy, and the Lacanian word of the father collide with demands of the feminist agenda.13 While these anxieties both feed upon and strengthen each other, they inadvertently pose questions about the validity of both the idealized notion of law generally held in our culture and the assumption that women in law act as a destabilizing force.

When Adam Bonner bluntly proclaims that "the law is the law" in Adam's Rib, he gives voice to this idealized assumption: namely, that law and the legal process, as guided by the U.S. Constitution, are more or less infallible, with a system of checks and balances ensuring that truth will prevail and justice will be served. As law professor and civil rights attorney David Kairys points out, law is popularly thought of and represented as "separate from—and 'above' politics, economics, culture, and the values or preferences of judges" (Kairys 1990, 1). This idealized model was long ago exposed as false by the school of jurisprudence known as legal realism and later by the Critical Legal Studies (CLS) movement, yet the debate remains generally limited to legal theory courses and law journals. If such commentary does enter mainstream discourse, as Kairys observes, it tends to occur only in terms of perceived "aberrant" instances of the court's having failed to align law with justice, thus ultimately reinforcing idealized assumptions about the law (Kairys 1990, 2). Such perceptions of law's legitimacy become crucial to the system's self-perpetuation.

Implicit within the idealized assumption is the notion that law needs little or no changing, that those alterations brought about by marginalized groups do, by definition, destabilize the system, and that those groups unused to wielding the power of the law inevitably will abuse and misuse that power, as Adam Bonner's lecture to his wife implies. Such groups ultimately will corrupt the finely tuned legal process that has been and continues to be "perfected" by lawmakers and guardians of the process—historically, white heterosexual males who have sculpted a system to best serve their needs and to maintain their fundamental power within the culture: "You start with one law then pretty soon it's all laws, pretty soon it's everything; then it's me." Like Adam's Rib, the contemporary female lawyer film generally accepts and promotes these assumptions, which necessarily work hand in hand to undermine the position of the female lawyer. Yet, in their (unconscious) attempts to do so, the films sometimes get caught up in complex cultural codes and contradictions, leading to uneasy resolutions in which the idealized sheen of the law may, in fact, be tarnished.

Extending from the fundamental public/private dichotomy built into the law are networks of gendered binaries or dualities—man/woman, reason/emotion, culture/nature, objectivity/subjectivity—that are so naturalized they come to structure law itself, thus supporting, reinforcing, and perpetuating the male paradigm that constitutes law, as Eisenstein has pointed out (Eisenstein 1988, 43). Rooted deeply in the patriarchal structure of Western religions, the sense of a natural order involving gender roles finds historical substantiation in U.S. Supreme Court decisions mobilizing notions of difference to support the public/private binary, thus ensuring that the public arena be reserved primarily for men.

The Court's 1873 decision in Bradwell v. Illinois, for instance, supports the State of Illinois' refusal to admit Myra Bradwell to the Illinois Bar. In his opinion, Justice Joseph Bradley expresses an especially strong need to designate the proper place for this woman, stating that "civil law as well as nature itself, has always recognized a wide difference in the respective spheres and destinies of man and woman. Man is or should be woman's protector and defender. The natural and proper timidity and delicacy which belongs to the female sex evidently unfits it for many of the occupations of civil life" (Taub and Schneider 1990, 163). Bradley's words seem chosen not only to render an opinion but also to instruct and castigate Bradwell herself—a mother of four, founder of the weekly Chicago Legal News, and an outspoken activist both in the suffrage movement and in the fight to remove "women's legal disabilities" in state legislation, as law professors Nadine Taub and Elizabeth M. Schneider point out (Taub and Schneider 1990, 161). A year later, Belva Lockwood was rejected by a number of law schools to which she applied "on the stated ground that women lacked the 'mentality' for legal study or would 'distract the attention of young men,'" according to feminist legal scholar Deborah Rhode (Rhode 1989, 21). Lockwood further encountered rejection by the Virginia Bar Association, after finally having gained admission to the National Law School, where she successfully completed her studies. The Virginia Supreme Court determined that "she was not a 'person' within the meaning of the state bar licensing statute" (Rhode 1989, 21). A similar reliance on difference was mobilized to support numerous disadvantages based on gender in the nineteenth and early twentieth centuries (Rhode 1989, 24)—a condition all too apparent when tracing the historical trajectory of women in law.

Only five women were practicing law in the United States in 1870, growing to barely more than a thousand at the turn of the century, with only twenty states allowing women to practice (Rhode 1989, 23). By 1930 approximately 3,385 women held law degrees in the United States, at that time only 2 percent of the national bar, while women accounted for over 23 percent of the total workforce (Sheffield 1993, 74). As one of the preeminent law schools in the nation, Harvard, until 1950, "remained inviolate" (Rhode 1989, 23). Women comprised less than 4 percent of the legal profession in the 1950s and 1960s, yet by 1975 women accounted for 25 percent of law students in the United States (Harrington 1994, 15). By the mid-1980s women comprised over a third of law students (Sheffield 1993, 95), a figure rising to nearly 50 percent by 1990 (Harrington 1994, 15), and in 2001, exceeding 50 percent (Carter 2002, 31). Indicative of popular attitudes in that same year, however, attorney Betty Ann Waters received significant media attention as a high school dropout, who, motivated by the murder conviction of her brother, not only pursued a law degree but also a teaching degree first so that she could finance her law school education and support her three children as a divorced parent. Upon discovering new DNA evidence and winning her brother's release, Waters was praised by the press in sentimentalized stories emphasizing her persistence in the name of family loyalty and love rather than in terms of her professional aptitude as a lawyer. Not surprisingly, her story is the subject of a movie under production, slated to star Naomi Watts.

Such perceptions and statistics are usefully traced through earlier popular discourse, beginning with post-World War II attitudes concerning the "new," independent career woman, which sparked both anxiety and altered outlooks. Rooted in many of the same traditional beliefs mobilized to prevent women from entering law at the turn of the century, postwar propaganda cautioned women contemplating careers that broken marriages and the juvenile delinquency of neglected children could result. Many working women of the period were strongly encouraged to retreat to the security and normalcy of the clean, sunlit kitchen, though as Elaine Tyler May points out, the numbers of women working actually expanded, "providing a potential alternative to early marriage and child rearing" (May 1988, 155). At the same time, "the continuing anxiety surrounding women's changing sexual and economic roles helps explain the unprecedented rush into family life and the baby boom of the postwar era" (May 1989, 167). This anxiety surrounding working women was, in part, connected to Cold War ideology, "since an essential ingredient in winning the cold war was presumably the rearing of strong and able offspring" (May 1989, 157). Film noir mediated this ideology with messages of caution that conveyed a mixture of fear and anxiety with regard to "treacherous" independent women. Such women were a particular source of tension, according to May, since it was thought that "outside the home, they would yield a dangerous, destructive force" (May 1989, 165).

In the 1980s and 1990s, despite some harrowing film portraits of independent career women gone berserk, Fatal Attraction-style, professional and working women did not retreat to the kitchen in great numbers, yet were pressured nevertheless to uphold "family values"—to live heterosexual, child-centered lives upon returning home from a day at the office. And the mainstream media, particularly women's magazines, instilled more than a small share of anxiety should women fail to achieve such a balance. Echoing 1940s wartime government pamphlets and women's magazines—in which the woman working for the war effort was told that "in her new independence she must not lose her humanness as a woman" (May 1989, 68)—1980s women's magazines constructed and valorized the "superwoman," cheering women on for achieving workplace ambitions while admonishing that business success should not hamper their roles a supermoms and wives. As in the 1940s, magazines of the 1980s instilled a sense of guilt rooted in inadequacy, now with an intensified emphasis on the body. The implicit message delivered was that career success for women could largely (or perhaps only) be attained through a woman's appearing and feeling both feminine and attractive. In her popular 1991 book, The Beauty Myth: How Images of Beauty Are Used against Women, Naomi Wolf argues that such discourse became a means of containing female empowerment, a condition especially evident in the case of high-profile female lawyers, for whom image and representation become sites of struggle where these tensions play themselves out.

The result of Marcia Clark's "remaking," as earlier noted, not only included her scripted comments to the press, designed to "motherize" Clark and erase any trace of gender-role ambiguity, but also involved her "performance" of femininity. Adopting the gestures and behaviors defined by our culture as unambiguously feminine and "girlish," Clark became less overtly threatening to the phallocentric institutions of law and the media—and, by extension, to the public, it would seem. Rather than appearing "grim, humorless, even angry . . . she smiled often, and incandescently. She laughed, even giggled, repeatedly. She rolled her eyes, cocked her head and shrugged her shoulders" (Margolick 1994, A10). The male journalist writing this article for the New York Times certainly notices the minute details of female gender performance, but in his failure to recognize, let alone analyze, the source of public anxiety shaping the "Remaking of the Simpson Prosecutor," he tacitly implies that Clark was, thankfully, now on track.

Leslie Abramson, attorney in the Erik Menendez case, was described in the mid-1990s as a "ferocious fist-pounder" (Foote and Hancock 1996, 66). Conversely, she was also frequently cast along stereotypical gender lines as ferociously protective and maternal in relationship to her youthful client, accused, along with his brother, of murdering his parents. While her "packaging" received less sustained media attention than did Clark's, one article appearing in Time reported public speculation that she had undergone a face lift, only to reveal that a subtle change in hairstyle had prompted the erroneous conclusion. The new hairstyle was suggested by television camera people who encouraged her to make the change during her stint as O. J. analyst on ABC, though she admitted preferring her hair "its usual, old way." Accompanying a blurb on Abramson's "littlest makeover," as the title announces, are "before" and "after" photos, inviting the reader to scrutinize Abramson entirely in terms of her physical attractiveness (Time 1995, 76).

Those female lawyer films in which the women never quite do get "on track," as Clark and Abramson did in real life, mobilize their own mechanisms of containment, usually in the form of misogyny, either subtle or overt. Often when the female lawyer fails to become sufficiently "motherized" or "feminized"—that is, when she fails to submerge the potential threat she poses to the legal system and to the men who are most identified with that system—she suffers violence or the threat of violence, most notably in Jagged Edge (1985), Suspect (1987), Physical Evidence (1988), Defenseless (1991), The Pelican Brief (1993), Guilty as Sin (1993), and The Client (1994). The professional and personal inadequacies of the female lawyer in film seem to both mediate historical and cultural anxieties and perhaps further elicit such anxieties, as the Marcia Clark "transformation" most notably confirms.

Beyond confronting media images that subtly communicate anxieties of inadequacy, working women from the 1980s forward have confronted the frustration of a firmly fixed glass ceiling, keeping many of them from attaining positions of genuine power within corporations and government organizations or from attaining partnerships in high-powered law firms. The statistics are numerous, but several examples concerning women in law tell the story. Barrister Magazine reported in 1991 that "women lawyers are far less likely to be promoted, get paid less, and express more dissatisfaction with their jobs than men," with a study of young lawyers showing that 45 percent of the men make partner, while only 18 percent of the women do (Rutledge 1991, 31). A 1995 study conducted by a panel of the American Bar Association indicated a further decline in opportunities for female lawyers, with promotion and salary rates lagging far behind those of their male counterparts, prompting one female attorney to remark that the statistics suggest "not a glass ceiling at the end, but a process that begins right off the bat" (Bernstein 1996, A9). And in 2001 the problem was perceived as "the second glass ceiling," with more women moving into law firm partnerships but not into positions of leadership (Carter 2002, 31). Rhode, as quoted by Carter, sees this as the "no-problem problem," in which the appearance of gender equity perpetuates inequity, given "a lack of consensus that there are serious problems" (Carter 2002, 31).

A 1991-1992 study of career and salary advancement of New York metropolitan-area lawyers reveals how the legal establishment used inaccurate perceptions of women with children to justify gender bias in earnings. The study shows that male lawyers with children—perceived as more stable than men without children—were rewarded with increased earnings, whereas female lawyers with children were perceived as less stable and therefore penalized by a decrease in earnings, an ironically revealing circumstance in light of the efforts to motherize Marcia Clark. Actual allocation of work effort by men and women with children was found to be equal (Dixon and Seron 1992, 28). A 1995 American Bar Association study notes that "in the private sector . . . very few lawyers—1 to 4 percent—dare to take advantage of the 'family friendly' policies adopted by most law firms in the last decade. Those who do are tarred as not seriously committed to the law," leading many female lawyers to feel "less willing to make extreme personal sacrifices to adapt to a work culture defined by white men" (Bernstein 1996, A9). Beyond such overt discrimination, many female lawyers experienced and continue to experience more subtle forms of exclusion "from male networks [which] reinforce the belief that women are less effective as 'rain makers,' lawyers who can bring in business," a perception extending back to law schools in which "women are effectively silenced by male law students who heckle them as 'femi-Nazis' and overwhelmingly male faculty who ignore them" (Bernstein 1996, A9). Such conditions led feminist legal theorist Cynthia Fuchs Epstein, writing in the early 1990s, to conclude that "few women escape the contradictory pressures and expectations within the profession and outside it. These pressures and contradictions—the products of ambivalence on the part of male gatekeepers and other men and women who do not believe that women belong in the law—create ambivalence in the minds of women" (Epstein 1993, 265).

Law, Patriarchy, and the Female Lawyer in Film

In an attempt to contain the "problem" of a potentially powerful woman mediating relationships through law and quite possibly modifying or changing the law, many female lawyer films of the 1980s and 1990s create their own mediating filter between the female lawyer and the full exercise of power within the law. Continually reminding us that patriarchy and law are inseparable, almost all female lawyer films feature patriarchal figures who possess the potency—the genuine power—to initiate the female lawyer into the structure of the law, to deny her access, or to regulate her behavior as she performs within or outside of the courtroom. These men, the films suggest, rightfully "own" the power of language and the law.

Intentionally or not, the female lawyer film has tapped into cultural anxieties concerning the continued survival and strengthening of the patriarchal network and the phallocentric institutions it supports. Typically, the films entrap the female lawyer between the word of a "good" and a "bad" father figure, both of whom compete to influence her. One measure of the female lawyer's growing consciousness and relative proficiency, both as a lawyer and as a human being, lies in her ability to identify and align herself with the good father—generally associated with the same liberal politics the films ostensibly adopt—thus overcoming her initial failure to recognize the bad father, often associated with reactionary politics and corrupt legal practice. Yet the simplistic polarities of "good" and "bad," as marked by the male patriarchs within the films, line up too neatly behind the equally simplistic categories of liberal and conservative.

The very presence of bad father figures within the legal institution, it would seem, exhibits a certain crisis in patriarchy, thus problematizing the apparent stability of law's patriarchal foundation. Yet the instructive powers of the good father work to reify the female lawyer within a more "stable" patriarchy by enlisting her support. If we agree with Rifkin—who defines patriarchy as "any kind of group organization in which males hold dominant power and determine what part females shall and shall not play" (Rifkin 1993, 412)—and with feminist legal theorist Diane Polan—who adds that this organization or system "is characterized by relationships of domination and submission, superiority and inferiority, power and powerlessness, based on sex" (Polan 1993, 425n)—then we can say that on an overtly narrative level the female lawyer film accepts law as patriarchal and the female lawyer as an inferior subject within that system, while simultaneously using the bad father as a means of questioning, or appearing to question, the apparent smoothness and coherence of the system. Moreover, the contradictory ideological polarities that tend to entrap the female lawyer also problematize patriarchy by sometimes unconsciously exposing its overdetermined narrative expression.

In male lawyer films like The Verdict, to be discussed in Chapters 1 and 5, the presence of a male lawyer as protagonist hegemonically stitches the tears in the patriarchal fabric, since this protagonist is unproblematically aligned with justice, even as he exposes the problematics of law. The female lawyer as protagonist, however, is a destabilizing presence who frequently is shown to subvert justice through her excess—either of emotion or of rationality, in the former case subverting both law and justice, while in the latter case upholding law at the expense of justice in the law/justice binary so often inscribed within the films. At best, tears in the patriarchal fabric are merely patched over in the female lawyer film—whether at the level of narrative closure or in terms of thematic representations of law and the legal process. Such tentative patching creates varying degrees of narrative instability, with overdetermined efforts at closure actually exposing potential weaknesses in the coherent and uncomplicated image of patriarchy the films may wish to convey.

Just as Adam Bonner lectures his wife on the law in Adam's Rib, scenes in which men instruct women in the law further inscribe a vague sense of patriarchy in crisis, while simultaneously attempting to "paper the cracks" of that crisis, as Wood aptly expresses it, through registering a general distrust of women as lawyers (see Wood 1986, 162-188). Clearly, a multilayered paradox is at work here. By implying limited knowledge on the part of the female lawyer, such scenes attempt to recuperate the power of patriarchy through the power of the law, both of which have been challenged by her presence. In addition to scenes of literal instruction delivered by male colleagues or superiors, repeated images in which the female lawyer confronts stacks of legal documents or leather-bound legal volumes likewise evoke the patriarchal authority under which the female lawyer operates. The classic design and frequent long-shot framing of imposing law libraries or cavernous courtrooms inscribe the law's immovable permanence. Coupled with camera movements along a vertical axis, the mise-en-scene further conveys a sense of phallic dominance and timeless tradition, uncritically supporting the hegemonic power of law, particularly in relationship to the female lawyer, who often stands dwarfed within the space of those legal institutions she so tentatively occupies. Such visual patterns reflect Rifkin's observation that "law, in relation to women, is seen as a measured and rational set of beliefs which at the same time asserts a mythological vision which is believed by many to present an accurate statement of the world" (Rifkin 1993, 413).

Confirming phallocentric dominance, when resolved, while simultaneously expressing an underlying sense of patriarchal crisis, the crimes typical of most female lawyer films center on the two bastions of patriarchy—the family and the legal system itself. When capable of resolving these crimes, the female lawyer restores power to the temporarily impaired patriarchy; when incapable of resolving them, she poses a threat that, in one way or another, must be neutralized. In this sense the female lawyer film enacts a subtle misogyny in its need to contain female potency, a misogyny reinforced by the conventional narrative structure of mainstream cinema, which, as feminist film scholar Kaja Silverman points out, often "is organized around a demonstration of the female character's castrated condition, a demonstration and interrogation which have as their ultimate aim the recovery of a sense of potency and wholeness for both the male character and the male viewer" (Silverman 1986, 229). In the case of the female lawyer film, a sense of recovery for the patriarchal legal system becomes a central if not fully realized aim as well.

One could argue that in adopting conventional narrative form, which places individual agency above collective agency or action, the female lawyer film further reifies its singular/"symbolic" female litigator within the dual patriarchal systems of law and of narrative, defining "success" for the female lawyer in terms of her "right" to gain access to both these systems as lawyer and as protagonist. The absence of women's collective agency within either system results from the structuring of narrative action around this individual female figure, who is surrounded and influenced by powerful men, while other female characters—typically cast as secretaries, legal assistants, or distraught clients—are relegated to the margins, revolving as satellites around the female lawyer, herself often displaced as a satellite within the larger system of the law. Although other female characters can complicate the female lawyer's status, the lack of anything approaching a female collective serves to strengthen inscriptions of patriarchal power. In addition, this trope of "the only woman in the firm" uses the marker of "exclusivity" to reinforce the legal, professional, and narrative status quo.

In the female lawyer film this notion of the singular woman who has gained access to the narrative and legal systems—where women traditionally have played peripheral roles—further reinforces a condition that pits gender against class and race, reflecting a similar condition in rights litigation, which involves "'claims staked within a given order of things' or 'demands for access for oneself and for "no admittance" to others'" (Schneider 1991, 323-324), as Elizabeth Schneider, quoting Rosalind Petchesky, points out. Posed as the real threat to white male authority, the white female lawyer in film, then, subsumes issues of race, class, and ethnicity, papering over a multiplicity of cracks in the system by posing gender as the singular "problem." Female lawyer films, moreover, present us with a woman who has had access to material comforts, education, and technology, thus casting the challenge to patriarchy in bourgeois terms, a challenge which itself is often coded or submerged. Such exclusivity and reductionism—both operating in the law and as reflected in representations of law in the female lawyer film—mask the fact that "because the law operates in support of both patriarchy and capitalism, people stand in different relationships to the legal system by virtue of their sex and class positions" (Polan 1993, 420). While films about the legal process frequently pose the law versus justice binary in terms of the client's marginal economic status, that narrative strategy further masks the issue of access denied marginal groups to positions of power within the legal system itself.

In attempting to retrieve a more stabilized position for phallocentric power within the law, the films train their focus not on such complex issues as class but on the female lawyer and her transgressions, primarily in her having abandoned the private for the public sphere, where she finds personal pain, in exchange for dubious fulfillment. Represented as professionally inadequate and personally unfulfilled—frequently unhappy, unmarried, and without children—the female lawyer is further seen as a potentially destabilizing force. While some female lawyers neurotically suppress their sexuality, others aggressively act upon their desires when they enter into romantic/sexual relationships with their clients, thus further compromising their effective practice of law. Interrogating the lawyer as woman first, the films suggest that, with lives so dangerously out of balance, female lawyers are interlopers who do not truly belong within the legal arena.

The problem of the female lawyer is very much like the problem of film noir women, whose ambitions and sexuality, neither molded nor restrained by marriage or children, pose a threat, "encouraging the spectator to take up a defensive position and to wish for the resolution of the [sexual] ambiguity, to put an end to the feelings of anxiety," as Pam Cook points out in her analysis of Mildred Pierce (Cook 1978, 78). Merging tendencies in film noir with those of the post-World War II melodrama, the more contemporary female lawyer films further register anxiety concerning maternal roles. Only four female lawyers have children, in all cases products of a troubled or broken home, with the young sons in Jagged Edge, Music Box (1990), and I Am Sam (2001) openly resenting their mothers' work and divided attention. Here the female lawyers' dedication to work is marked as obsessive, though that same dedication is often represented as ennobling in the classic male lawyer film, mediating in reverse, it would seem, the falsely held impressions of female and male lawyers with children expressed in the study previously cited.

In conflating representations of the film noir female with what Jackie Byars calls "the Woman Alone" of 1950s melodrama, a number of female lawyer films reinstate a stable order only when the lawyer discovers the love of a good man who neutralizes her ambitions. Tracing shifting social conditions and attitudes that helped shape representations of the Woman Alone, Byars observes that she "suffers, but does it with dignity" (Byars 1991, 76) in the 1930s and 1940s, often sacrificing her own happiness for that of her children or for higher moral values. In the 1950s, however, when many more married women were working outside the home, but when popular discourse promoted the traditional matrimonial arrangement of woman-at-home/man-at-work as the cultural ideal, the Woman Alone became "a love-starved pariah," observes Byars, quoting Marjorie Rosen (Byars 1991, 76). Her motives for working outside the home "became associated less with necessity than with moral inadequacy" (Byars 1991, 89), a pattern, though somewhat modified, that nevertheless finds expression in the more recent female lawyer film.

At various points throughout this study, the melodrama and film noir—two powerfully resonant film groups of the postwar era that register the tensions of women living in patriarchy—will serve as lenses through which to view the 1980s and 1990s female lawyer film. In addition, structural conventions of the American film musical, unlikely though it may seem, will provide a useful means of understanding the narrative structure of a number of female lawyer films that invite comparison of the female lawyer to a male character, against whom she is measured and by whom she is sometimes displaced as protagonist.

Studying the Female Lawyer Film: Genre, Spectatorship, and the Law

By their very presence, women in law throw into relief the condition of women in patriarchal culture, whether in terms of female gender performance or female agency, as both are inflected and regulated by the law and conventional narrative form. The female lawyer's (in)ability to "author" versions of truth when constructing legalistic courtroom narratives inscribes her complicated position as a woman in law, while simultaneously exposing the sometimes precarious yet historically tenacious position of patriarchal dominance in law and in cinema. Founded on the male as author of the story and as owner of the look, both institutions rely upon male-constructed narratives and the interrogatory male gaze to serve and to perpetuate existing power structures within those institutions.

In tracing these patterns, Chapter 1 will examine at length two disparate but nevertheless informative precursors to the main body of more recent female lawyer films: George Cukor's 1949 screwball comedy Adam's Rib and Sidney Lumet's 1982 courtroom drama The Verdict, a male lawyer film that, in fascinating ways, anticipates many tropes of the female lawyer film to follow.

The implications of patriarchy and phallocentrism as defined, in part, through Jacques Lacan and understood in the context of American culture and law are issues that Chapters 2 and 3 will explore through the study of four female lawyer films of the 1990s: Music Box (1990), Class Action (1991), The Client (1994), and Defenseless (1991), all of which mediate these implications in complex ways.

Chapters 4 through 6 will explore the ways in which the "laws" of patriarchy and of phallocentric power converge with the "laws" of film genre, through a study of female lawyer films that "cross-pollinate" with various other genres, among them, the psychological thriller: Jagged Edge (1985) and Guilty as Sin (1993); the investigative romance: The Big Easy (1987), Suspect (1987), and Physical Evidence (1988); the action romance: The Pelican Brief (1993), Fair Game (1994), and Conspiracy Theory (1997); and the romantic comedy: Legal Eagles (1986), Curly Sue (1991), and Other People's Money (1991). Female lawyer films of the 1980s and 1990s will further be considered in light of the courtroom drama, through a brief look at female lawyer films of the 1920s and 1930s and at the male lawyer film in both its classic and contemporary incarnations. Not only do conventions of the classic male lawyer film inflect female lawyer narratives, but more significantly, traces of the female lawyer film are sketched upon the canvas of contemporary male lawyer films, fracturing slightly the unified, coherent representation of the law and of unmitigated male agency within the law, as particularly evident in Presumed Innocent (1990), A Few Good Men (1992), The Firm (1993), The Rainmaker (1997), and The Devil's Advocate (1998).

Genre theory and legal theory converge to uncover the patriarchal unconscious at work in both female and male lawyer films, at the same time allowing for a contemplation of the pleasures inherent in both film genre and in law. Just as our pleasure in genre, to a large degree, resides in an interplay of willing engagement with a set of relatively predictable "rules" or conventions and resistance to the limitations of these conventions, so too our pleasure in law arises from a similar interplay of engagement and resistance. Such issues will inform a discussion of spectatorship and feminist address, concerns interwoven throughout this book but explored most directly in Chapter 7 through the study of three films: The Accused (1989), Love Crimes (1992), and Female Perversions (1997), the latter two directed by women. All three films directly engage with feminist concerns and issues of spectatorship.

It is within this area of spectatorship that my own intense personal interest lies. In 1991, when writing a review of Class Action, I was struck by my contradictory responses to the film. Initially I was pleased to encounter an intelligent female protagonist onscreen, surrounded, it seemed, by male colleagues aware of and comfortable with her knowledge and her status as she competently argued a point of law or confidently traversed the corridors of power. Surely this and other images of professional, independent female lawyers I remembered somewhat fuzzily from films of the 1980s presented an affirming experience. Yet, as the story of Class Action unfolded and I began composing the review in my mind, the film's confused politics began to perplex me. While presenting itself as politically liberal, not the least in its positioning of a female lead as an independent professional woman, the film ultimately turned against its protagonist, exposing her failure in measuring up to its own liberal politics. Through that failure the film revealed her inadequacies—both as a woman and as a lawyer.

Tangled in this net of contradictions, I found only the most precarious of grounding as I searched for a narrative space that would allow me to align myself with this ostensibly powerful woman. Prompted by a conversation with a colleague, I began to revisit those earlier films of the 1980s, which, on second viewing, presented much the same nagging difficulty. Something beyond the frequently cited Hollywood antifeminism was operating in these films, and that something, I have come to believe, has much to do with the discourse on law and "ownership" of the law that many of these films seek to offer. Exploring the films in terms of antifeminist tendencies, I became slowly conscious of a crisis in patriarchy that they were inadvertently expressing. It is within this very contradiction that the "viewing space" I was seeking seemed to reside.

It is my hope that as the following chapters uncover such contradictions, a fruitful dialogue will emerge as feminist legal theory and feminist film theory, Critical Legal Theory and film genre theory, "speak" to each other—a dialogue richly revealing of the cultural, political, and institutional landscape in which they exist and a dialogue charged with the power to carve out additional productive "viewing spaces" within the terrain of the films we will study.